IR 05000454/2020001

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Integrated Inspection Report 05000454/2020001 and 05000455/2020001
ML20115E528
Person / Time
Site: Byron  Constellation icon.png
Issue date: 04/24/2020
From: Hironori Peterson
Division Reactor Projects III
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2020001
Preceding documents:
Download: ML20115E528 (23)
v • d • e


Text

April 24, 2020

SUBJECT:

BYRON STATION - INTEGRATED INSPECTION REPORT 05000454/2020001 AND 05000455/2020001

Dear Mr. Hanson:

On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Byron Station. On April 14, 2020, the NRC inspectors discussed the results of this inspection with Mr. M. Kanavos, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Byron Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Byron Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Hironori Peterson, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37 and NPF-66 Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Byron Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Entry Into a High Radiation Area Where Dose Rates Had Not Been Determined.

Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.5] - Work 71124.01 Radiation Safety NCV 05000455/2020001-01 Management Open/Closed A finding of very low safety significance (Green) and an associated non-cited Violation of 10 CFR 20.1601 was self-revealed when the licensee failed to control access to a high radiation area, and an individual made entry into areas within that high radiation area where dose rates had not been determined. This resulted in the individual receiving dose and dose rate alarms on their electronic dosimetry which resulted in unnecessary radiation exposure.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period operating at full power. With the exception of minor reductions in power to support scheduled testing activities, load changes requested by the transmission dispatcher, and coast down in preparation for a planned refueling outage, the unit remained at or near full power. On March 8, 2020, the unit began a refueling outage. The unit went critical again on March 26, 2020. The unit was returned to full power on March 30, 2020.

Unit 2 began the inspection period operating at full power. With the exception of minor reductions in power to support scheduled testing activities or load changes requested by the transmission dispatcher, the unit remained at or near full power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/readingrm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. From January 1 - March 19, 2020, the inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 2A train of containment spray (CS) during a 2B CS train work window on January 15, 2020
(2) Unit 1 component cooling (CC) water system on February 19, 2020
(3) Unit 2 spent fuel pool cooling system on March 12, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 safety injection system on March 16, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) FZ 11.30-0, Auxiliary Building, 364' elevation, on March 4, 2020
(2) FZ 18.3-1, Unit 1 Main Steam and Auxiliary Feedwater Pipe Tunnel on March 5, 2020
(3) FZ 11.5A-1, 11.5B-1, Auxiliary Building, 414'-0" elevation, Unit 1 Electrical Penetration Area on March 12, 2020
(4) FZ 5.5-1, Auxiliary Building Auxiliary Electrical Room - 451' elevation, on March 13, 2020
(5) FZ 8.6-0, Turbine Building NorthWest Center, 451' elevation, on March 20, 2020

71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)

Main article: IP 71111.08
(1) The inspectors verified the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary were appropriately monitored for degradation and repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from March 9, 2020 to March 24, 2020:

03.01.a - Nondestructive Examination and Welding Activities.

  • Ultrasonic, volumetric examination of weld 1CS23AB-14 C29, category R-A, item R1.20, using the performance demonstration initiative procedure PDI-UT-2 for austenitic stainless steel
  • Ultrasonic, volumetric examination of weld 1SI34A-8/C05, category R-A, item R1.20, using PDI-UT-2
  • Liquid penetrant, surface examination of weld 1SI08JA-1.5W-15A, ASME class 1, category B-K, item B10.20, piping to penetration weld located in the reactor building
  • No flaws were evaluated and accepted for continued service for this unit and during this inspection timeframe
  • Pressure boundary weld number 1 for work order 04933373 task 01 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.
  • Bare metal visual examinations were conducted on penetrations 1-78 and on the head vent penetration. Sampled completed penetration exam photographs, videos, and records for head penetrations 25, 50, 32, 27, and 14
  • Volumetric head penetration examinations were conducted on penetrations 1-78 and on the head vent penetration. Sampled in-process penetration data including time of flight diffraction acquisition and analysis for penetrations 39 and 76
  • There were no reactor head penetration examinations with indications accepted for continued service during this in-service inspection
  • There were no reactor head penetrations with welded repairs during this in-service inspection 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
  • Boric acid evaluations and corrective actions were reviewed for components 1CS009B and 1SI097
  • NRC resident inspector boric acid observations were compared with licensee identified boric acid concerns identified upon the containment down-posting 03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.
  • There were no tubes subjected to in-situ pressure testing

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during the Unit 1 cooldown heading into outage B1R23, auxiliary feedwater surveillance testing, Ovation cutover evolutions, pressurizer draindown operations, and rod drop testing during the time period of March 9, 2020 to March 26, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator requalification training on February 25, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;

(1) 1B diesel generator (DG) exhaust leak on January 15, 2020
(2) 1B DG repairs on January 22, 2020
(3) 2B charging (CV) pump work windows on January 28, 2020
(4) Shutdown cooling protected equipment walkdown with pressurizer level less than 5 percent and Yellow shutdown outage risk on March 11, 2020
(5) Mode change following B1R23 startup with the 1B auxiliary feedwater pump inoperable on March 28, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) AR 04299366, Impact of Westinghouse A200 Series Contractors on January 3, 2020
(2) 1B DG operability following exhaust manifold bellows failure on January 16, 2020
(3) AR 04313465, Debris discovered in 2B CV mechanical seal cooling line outlet on January 31, 2020
(4) AR 04326254, 1AF014B failed leak rate criteria on March 16, 2020
(5) AR 04329592, Urgent Failure during NF-BY-510 on March 28, 2020

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Modified 1B DG Exhaust Manifold Support on January 27, 2020
(2) Temporary Configuration Change for the Ovation modification prior to full installation on February 28, 2020
(3) 6G-19-005/BRW-E-2019-32, Use of Auxiliary Feedwater at Low Power, on January 3, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) 1B DG post maintenance run on January 31, 2020
(2) 2B CV pump PMT on January 31, 2020
(3) 1A component cooling water (CC) pump following work window on February 3, 2020
(4) Unit 1 physics testing on March 26, 2020
(5) 1B auxiliary feedwater pump full flow testing following starter motor replacement on March 30, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated Outage B1R23 activities from March 8, 2020 to March 26, 2020. Due to the actions in response to the COVID-19 National Health Crisis, inspectors could not complete Section 03.01.d.2 of Inspection Procedure

===71111.20 for B1R23. Specifically, a containment closeout walkdown prior to Unit 1 start up was not completed.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22
(1) 2B AFW Monthly Surveillance on February 10, 2020
(2) 1BOSR 8.1.9-1, 1A DG Safe Shutdown Sequencing and Single Load Reject, on March 18, 2020
(3) Rod drop testing on March 25, 2020 Inservice Testing (IP Section 03.01) ===
Main article: IP 71111.20
(1) 1BOSR 5.5.8.AF.5-1C, Comprehensive Inservice Testing Requirements for the Motor Driven Auxiliary Feedwater Pump 1AF01PA, on March 5, 2020

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Local leak rate testing of PS229A using 1BOSR 6.1.1-8, Primary Containment Type C Local Leakrate Tests and IST Tests of Primary Sampling System, on March 12, 2020

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) EP Focused Area Drill in the Technical Support Center on February 11,

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (1 Partial)

The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.

(1) (Partial)

Observed workers surveying and replacing OMNI pusher reels and other activities on steam generator platforms during Unit-1 refueling outage under RWP BY-1-20-00710.

Radiological Hazards Control and Work Coverage (IP Section 03.04) (2 Partials)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) (Partial)

Steam generator activities under RWP-BY-1-20-00710; March 17, 2020.

(2) (Partial)

Core barrel moves was observed remotely under RWP-BY-20-00648; March 16, 2020.

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (1 Partial)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) (Partial)

Unit 2 containment entry, March 27, 2019.

71124.05 - Radiation Monitoring Instrumentation

Walk Downs and Observations (IP Section 02.01) (1 Sample)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Portable Survey Instruments
  • Ludlum 177 GM Detector S/N 0018170; Calibration Due Date 06/17/2020
  • Ludlum 3030 Alpha/Beta Counter S/N 0023592; Calibration Due Date 03/04/2020
  • Telepole S/N 0023590; Calibration Due Date 03/07/2020
  • Telepole S/N 0018067; Calibration Due Date 02/27/2020
  • Thermo Eberline RO-20 S/N 0016555; Calibration Due Date 03/29/2020
  • REM Ball/Red Eye Model PX S/N 002725; Calibration Due Date 08/26/2020 Source Check Demonstration
  • ARGOS 5 Personnel Contamination Monitor (PCM) at Radwaste Area ID-282; Calibration Due Date 07/08/2020
  • ARGOS 5 PCM at Chemistry Department ID-140; Calibration Due Date11/17/2020
  • PM-12 Gamma PCM S/N 1251; Calibration Due Date 04/02/2020
  • SAM-12 Small Article Monitor S/N 94; Calibration Due Date 12/01/2020
  • SAM-9/11 Small Article Monitor S/N 234A; Calibration Due Date 06/14/2020
  • FAST Scan I and FAST Scan 2 whole body counter (WBC); Calibration Due Date 03/20/2020 Area Radiation Monitors and Continuous Air Monitors
  • 1AR-012; Containment Building Fuel Handling Incident Radiation Monitor
  • 2AR-011; Containment Building Fuel Incident Radiation Monitor
  • 0AR-055; Fuel Building Fuel Handling Incident Radiation Monitor
  • ARGOS 2-B at elevation 931' Turbine Building; Calibrated on 09/12/2019
  • Three Small Article Monitors (SAMs)

Calibration and Testing Program (IP Section 02.02) (1 Sample)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors
  • Small Article Monitor (SAM); Source Checked on 09/12/2019
  • ARGOS 2-B at elevation 931' Turbine Building; Calibrated on 09/12/2019 Failure to Meet Calibration or Source Check Acceptance Criteria
  • MGP Telepole 6608-081 Out of Tolerance

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===

Main article: IP 71151
(1) Unit 1 Unplanned Scrams per 7000 Critical Hours (January 1, 2019 -

December 31, 2019)

(2) Unit 2 Unplanned Scrams per 7000 Critical Hours (January 1, 2019 -

December 31, 2019)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

(2 Samples)

(1) Unit 1 Unplanned Power Changes per 7000 Critical Hours (January 1, 2019 -

December 31, 2019)

(2) Unit 2 Unplanned Power Changes per 7000 Critical Hours (January 1, 2019 -

December 31, 2019)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 1 Unplanned Scrams with Complications (January 1, 2019 - December 31, 2019)
(2) Unit 2 Unplanned Scrams with Complications (January 1, 2019 - December 31, 2019)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Notification of code non-conformance for replacements steam generators on March 9, 2020
(2) Westinghouse control rod drive mechanism thermal sleeve failure 10 CFR Part 21 notification on March 27,

INSPECTION RESULTS

Entry Into a High Radiation Area Where Dose Rates Had Not Been Determined.

Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.5] - Work 71124.01 Radiation Safety NCV 05000455/2020001-01 Management Open/Closed A finding of very low safety significance (Green) and an associated non-cited Violation of 10 CFR 20.1601 was self-revealed when the licensee failed to control access to a high radiation area, and an individual made entry into areas within that high radiation area where dose rates had not been determined. This resulted in the individual receiving dose and dose rate alarms on their electronic dosimetry which resulted in unnecessary radiation exposure.

Description:

On March 27, 2019, an entry into the Unit 2 containment was conducted to perform pre-refueling outage inspections. Unit 2 containment was posted and controlled as a locked high radiation area (LHRA). This entry consisted of a group of individuals with support provided from several radiation protection technicians (RPTs). Radiation Work Permit (RWP)2-19-210, Pre-Outage Activities @ Mode 1 - OMB [outside missile barrier] Work Only, was used for the entry. Radiological setpoints for this RWP were 30 mrem and 75 mrem/hr for gamma exposure and 10 mrem and 25 mrem/hr for neutron exposure.

At 8:00 a.m. on March 27, 2019, a pre-job radiological brief was conducted for the individuals by a RPT. This brief outlined that RPTs would provide support but not continuous coverage for the workers. Additionally, the radiological conditions were discussed for the areas within Unit 2 containment where the inspections were to occur. It was verbally communicated to the group that an area on the 412 elevation outside the missile barrier (OMB) was not to be entered, as radiological conditions were elevated but not measured or determined.

Radiological conditions in this area were high due to the presence of Chemical and Volume Control System (CVCS) lines in the area. The entrance to this area was identified by the presence of a turnstile. The turnstile was not locked, posted, nor controlled.

During the job evolution, one engineer passed through the turnstile on the 412 OMB and entered the area that was not expected to be entered. While performing inspections in this area, the engineer received dose rate alarms from the higher radiation levels. The dosimeter stopped alarming when the engineer exited areas having radiation levels above the alarm setpoint (75 mrem/hr from gamma radiation). The highest dose rate recorded by the electronic dosimeter was 2510 mrem/hr (gamma). The engineer received a separate, continuous alarm when the electronic dosimeter exceeded the total dose alarm setpoint of 30 mrem from gamma radiation. The electronic dosimeter measured a total radiation dose of 78.8 mrem (gamma) from the individuals activities. The individual exited the 412 elevation of the Unit 2 containment and subsequently the Containment Building, with the electronic dosimeter in continuous alarm.

Corrective Actions: The engineers access to the Radiologically Controlled Area (RCA) was terminated. The licensee improved supervisory oversight of High Radiation Area briefs and improved RPT coverage of select work groups while performing work in High Radiation Areas. Lastly, the workers are now required to demonstrate via the usage of radiological survey maps the location(s) of intended work.

Corrective Action References: AR04233626

Performance Assessment:

Performance Deficiency: The licensee failed to control access to a high radiation area, and an individual made entry within that high radiation area where dose rates had not been determined. This resulted in the individual not being knowledgeable of current radiological conditions.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation.

Specifically, the worker entered an area where the current dose rates were not determined.

This resulted in the individual not being knowledgeable of current radiation conditions and led to unintended dose. The inspectors reviewed IMC Chapter 0612 Appendix E, Examples of Minor Issues, dated 01/01/2020. Example 6.g describes a performance deficiency involving a worker improperly entering a posted HRA or LHRA, that is similar to this event. In this example, the performance deficiency is determined to be more than minor if an improper entry was made into a LHRA. In the actual event, an improper entry was made into a LHRA.

Consequently, the inspectors concluded the issue was more than minor.

Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The inspectors determined that the finding was of very low safety significance (Green) because:

(1) it did not involve as-low-as-reasonably-achievable planning or work controls,
(2) there was no overexposure,
(3) there was no substantial potential for an overexposure, and
(4) the ability to assess dose was not compromised.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee did not implement an effective process to ensure the locked high radiation area on the 412' outside missile barrier area in the Unit 2 containment was adequately controlled.

This allowed access to an area of unknown radiological conditions by a worker.

Enforcement:

Violation: Title 10 CFR 20.1601(a) requires, with exceptions not applicable here, that the licensee ensure that each entrance to a high radiation area (HRA) has one or more of the following features:

(1) A control device that, upon entry into the area, causes the level of radiation to be reduced below that level at which an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates;
(2) A control device that energizes a conspicuous visible or audible alarm signal so that the individual entering the high radiation area and the supervisor of the activity are made aware of the entry; or
(3) Entryways that are locked, except during periods when access to the areas is required, with positive control over each individual entry.

Title 10 CFR 20.1601(b) states that in place of the controls required by paragraph

(a) of this section for a high radiation area, the licensee may substitute continuous direct or electronic surveillance that is capable of preventing unauthorized entry.

Title 10 CFR 20.1101(a) states that each licensee shall develop, document, and implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of this part.

Procedure NISP-RP-05, Access Controls for High Radiation Areas, Revision 1, which is part of the licensees radiation protection program and which describes positive control per 10 CFR 20.1601(a)(3), contains the following requirements (in part) for access to a high radiation area:

Step 5.1 Provide each individual, or group of individuals if permitted by technical specifications, entering an HRA or LHRA with one of the following:

Step 5.1.1 A radiation monitoring device that continuously indicates the radiation dose rate in the area.

Step 5.1.2 A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received; entry into such areas with the monitoring device may be made after the dose rates in the area have been determined and personnel have been made knowledgeable of them.

Step 5.1.3 An individual qualified in radiation protection procedures with a radiation dose rate monitoring device; this individual is responsible for providing positive radiation protection control over the activities with the area and should perform periodic radiation surveillance at the frequency specified in the radiation protection procedures or the applicable RWP.

Step 5.2 Conduct HRA/LHRA briefings for personnel entering the area to ensure an understanding of expected dose rates and protective measures.

Contrary to the above, on March 27, 2019, the licensee failed to control access to the 412' elevation outside the missile barrier of the unit 2 containment, a High Radiation Area with an estimated radiation level of 2510 mrem/hr by any of the methods in 10 CFR 20.1601(a) or (b),with exceptions not applicable here, and as specified in Procedure NISP-RP-05, Revision 1.

Specifically, personnel entered the area and did not have a radiation monitoring device that continuously indicates the radiation dose rate; nor were the dose rates in the area determined and personnel made knowledgeable of them; nor were the personnel with an individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who provided positive radiation protection control.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Notification of Code Nonconformance for Replacements Steam 71152 Generators The inspectors performed a detailed review of Issue Report (IR) 4272501, Notification of Code Nonconformance for Replacements Steam Generators. The manufacturer of the licensees replacement steam generators (RSGs) for Byron Unit 1 had recently identified that volumetric examination of a nozzle weld repair that was accomplished by the manufacturer prior to the delivery of the RSGs to the licensee had not been performed, contrary to American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III, Class 1, requirements. The affected nozzles were the 3-inch diameter blowdown and recirculation nozzles. The nozzles were fabricated by weld metal buildup as permitted by NB-4244(c). The manufacturer determined that the nozzles required repair of surface indications; the manufacturers records did not indicate the depth of the excavations and no post-repair volumetric examinations were performed.Section III, Division 1, Subsection NB-4453.4 of the ASME Boiler and Pressure Vessel Code requires a volumetric exam when the excavation exceeds the lesser of 10 percent of the section thickness or 3/8 inch. For this Problem Identification and Resolution Annual Sample, the inspectors focused on assessment of the licensees corrective actions taken to date and those planned from this point forward.

The licensee performed an engineering change which included an ASME code class reconciliation for the 3-inch diameter blowdown and recirculation nozzles. This reconciliation involved a section by section evaluation applicable to nozzle weld buildups to determine the ASME Code Class 1 versus the ASME Code Class 2 requirements. The licensee determined based on their code class reconciliation that the blowdown and recirculation nozzles could be classified as ASME Code Class 2 (Subsection NC). Since Section III, Subsection NC (4453.4 and 5254), of the ASME Boiler and Pressure Vessel Code requires volumetric examination for nozzle weld buildups after weld repair only if the nozzles diameter is 6-inch or greater, this code reconciliation resolved the ASME Code nonconformance.

The inspectors concluded that the licensees actions taken in accordance with their correction action program were reasonable given the overall safety significance of the issue. The inspectors did not identify any findings or violations of NRC requirements in the course of their review.

Observation: Westinghouse Control Rod Drive Mechanism Thermal Sleeve 71152 Failure 10 CFR Part 21 Notification The inspectors performed a detailed review of IR 4304789; Part 21-Westinghouse Thermal Sleeves, IR 4320104, WEC NSAL-20-1, RVH CRDM Penetration Thermal Sleeve Failure, IR 4322068, Westinghouse Justification to Postpone NSAL-20-1 Inspections and IR 4327728, Thermal Sleeve at Pen-34 Lowered Beyond Specific Eval Value.

The sample selected was associated with a 10 CFR Part 21 notification to the NRC (Westinghouse LTR-NRC-19-79, dated December 12, 2019; ADAMS Accession No.

ML19346H873) and additional information on the 10 CFR Part 21 in Nuclear Safety Advisory Letter (NSAL) NSAL-20-1, "Reactor Vessel Head Control Rod Drive Mechanism Penetration Thermal Sleeve Cross-Sectional Failure" dated February 14, 2020 (ADAMS Accession No.

ML20063J583). The specific issue was associated with mechanical fatigue and fracture that leads to flange separation of thermal sleeves in the control rod drive mechanism penetration tubes which could have a safety consequence that was not previously considered.

The licensee performed an evaluation of the actual thermal sleeve wear measurements taken at thermal sleeve penetrations during the Spring Unit 1 2020 outage versus the NSAL-20-1 lowering criteria. All thermal sleeve penetrations were within the lowering criteria as described in NSAL-20-1 with the exception of the thermal sleeve at penetration 34. The licensee performed an additional evaluation of the thermal sleeve at penetration 34 which had lowered beyond the NSAL-20-1 lowering criteria. The inspectors reviewed the evaluations and consulted with technical staff from the Office of Nuclear Reactor Regulation (NRR). No findings or violations were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On April 14, 2020, the inspectors presented the integrated inspection results to Mr. M. Kanavos, Site Vice President, and other members of the licensee staff.
  • On February 7, 2020, the inspectors presented the radiation protection baseline (radiation monitoring) inspection results to Mr. K. McGuire, Operations Director, and other members of the licensee staff.
  • On February 27, 2020, the inspectors presented the radiation protection baseline inspection results to Mr. M. Justice, Acting Operations Director, and other members of the licensee staff.
  • On March 24, 2020, the inspectors presented the Inservice Inspection Exit B1R23 inspection results to Ms. Z. Cox, Regulatory Assurance Manager, and other members of the licensee staff.
  • On April 3, 2020, the inspectors presented the radiation protection baseline inspection results to Mr. J. Reed, Radiation Protection Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Corrective Action AR 04327209 1SI8853A Failed as Found Pressure Test 03/17/2020

Documents

Miscellaneous BOP CC-M1 Unit 1: Component Cooling System Valve Lineup 28

BOP CC-M2 Unit 2: Component Cooling System Valve Lineup 23

BOP CS-M2 Valve Lineup 11

BY-A4-002 One Time Unique Configuration Risk Assessment for 1

One-Half 1VA01SB SX Cubicle Cooler Maintenance

Procedures 0BOA Refuel - 3 Loss of Spent Fuel Cooling Unit 0 4

BAR 1-1-A1 Spent Fuel Pit Pump Trip 53

BAR 1-1-B1 Spent Fuel Pit Temp High 3

BAR 1-1-C1 Spent Fuel Pit Level High Low 5

BOP FC-M1 Fuel Pool Cooling and Cleanup System Valve Lineup 17

BOP FC-T2 FC System One-Line Diagram 3

71111.05 Fire Plans Pre-Fire Plan FZ 11.3-0, Auxiliary Building 364'-0" Elevation General Area 4

  1. 111 - South

Pre-Fire Plan FZ 11.3-0, Auxiliary Building 364'-0" Elevation General Area 4

  1. 112 - West

Pre-Fire Plan FZ 11.3-0, Auxiliary Building 364'-0" Elevation General Area 4

  1. 113 - North

Pre-Fire Plan FZ 11.5A-1; Aux. Bldg. 414'-0 Elev. Unit 1 Electrical 3

  1. 152 Penetration Area

Pre-Fire Plan FZ 18.3-1, Unit 1 Main Steam and Auxiliary Feedwater Pipe 3

  1. 197 Tunnel

Pre-Fire Plan #49 FZ 5.5-1; Aux. Bldg. 451'-0" Elev. Unit 1 Auxiliary Electrical 3

Room

Pre-Fire Plan #85 FZ 8.6-0, Turbine Building 451'-0" Elevation Unit 2 General 3

Area - NE Center

71111.08P Corrective Action AR 01190551 FME - 1FW540 Cage Pin Retaining Spring Found Broken 03/22/2011

Documents AR 04173407 Past Operability Review of SGLLS Shim Issue -Unit 1 10/04/2018

AR 04174489 Cracked Shim Plate Tack Weld on Support 1RC-01-BD-LLR 09/18/2018

AR 04328020 Foreign Objects Found in B SG Secondary Side -B1R23 03/19/2020

71111.08P Engineering 0000403234 B1R20 SG Pre-Mode 4 / Final Condition Monitoring 09/27/2015

Inspection Type Designation Description or Title Revision or

Procedure Date

Changes Operational Assessment

EC 0000630417 B1R23 Degradation Assessment 1

Engineering Component Evaluation of Leakage from Bolted Connection 10/16/2019

Evaluations 1CS009B

Component Evaluation of Leakage of Quick Connect Downstream High 10/20/2018

1SI097 Point Vent Valve

Procedures 54-ISI-603-011 Automated Ultrasonic Examination of RPV Closure Head 11

Penetrations Containing Thermal Sleeves

ER-AA-335-002 Liquid Penetrant (PT) Examination 11

ER-AP-331 Boric Acid Corrosion Control (BACC) Program 10

ER-AP-331-1001 Boric Acid Corrosion Control (BACC) Inspection Locations, 11

Implementation and Inspection Guidelines

ER-AP-331-1002 Boric Acid Corrosion Control Program Identification, 11

Screening and Evaluation

ER-AP-420-001 Byron/Braidwood/Ginna Unit 1 and Calvert Cliffs Units 1 & 2: 15

Steam Generator Eddy Current Activities

ER-AP-420-0051 Conduct of Steam Generator Management Program 23

Activities

EXE-PDI-UT-2 Ultrasonic Examination of Austenitic Piping Welds in 8

accordance with PDI-UT-2

SGP-PLG-RIB- Mechanical Ribbed Plugging of Steam Generator Tubes 4.1

FP-GEN

SGP-PLG-RIB- Steam Generator Tube Plugging Procedure Specification for 1

PS-GEN Expanded Ribbed Mechanical Plugs

WDI-STD-1013 Remote In Service Inspection of Reactor Vessel Nozzle to 3

Safe End, Nozzle to Pipe and Safe End to Pipe Welds Using

Nozzle Scanner

WDI-STD-1165 Remote Inservice Inspection of Reactor Vessel Nozzle to 0

Safe End, Nozzle to Pipe, and Safe End to Pipe Welds Using

Athena Phased Array System

Work Orders 04933373-01 MVR 1MS081C Cut/Plug/Weld MS Vent Tap per EC 60974 03/17/2020

1731155-12 B1R20 - Replace Body to Bonnet Gasket (1SI8877A) 09/16/2018

4618605-09 Active Packing Leak on 1RH8701B 09/23/2018

WO 04832096 01 CM- Weld Shim Plate Assembly on Support 1RC01BD-LLR 09/20/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.13 Miscellaneous EDG1B Fire Zone List; pgs. 193-194

Procedures 1BOL 8.1 Checklist B; 1B DG 14 Day AOT Checklist 23

71111.15 Corrective Action AR 04277757 Potential Part 21 Westinghouse Contactors 09/09/2019

Documents AR 04299366 Impact of Westinghouse A200 Series Contactors 11/22/2019

AR 04310359 Early Shutdown of the 1B DG Due to Excessive Exhaust 01/15/2020

Leak

AR 04313465 Debris Discovered in 2CV01PB Mech Seal Cooling Line 01/28/2020

Outlet

AR 04313465 Debris discovered in 2CV01PB Mech Seal Cooling Line 01/28/2020

Outlet

AR 04326254 1AF014B Failed Leak Rate Testing 03/13/2020

Engineering 0000630419 Lifting AR-VD62X Trip Contact for DG Room 1B Supply Fan 01/16/2020

Changes 1VD01CB

Engineering EC 630528 Lost Parts Evaluation 2BCV Pump Mechanical Seal Debris 0

Evaluations

Miscellaneous AR 04310359 SOC Daily MRC Report 01/21/2020

BYR-2-2020- Risk Assessment for 2B CV pp Seal 01/30/2020

0040

EXEPWR-19-4; Westinghouse Nuclear Safety Advisory Letter, NSAL-19-2 09/04/2019

EXEBWR-19-4

Operability AR 04310359 Early Shutdown of the 1B DG Due to Excessive Exhaust 01/15/2020

Evaluations Leak

EC 355386 Technical Evaluation - Fuel Impact - Potential Debris 0

Intrusion From SI Hot Tap Installation (Byron Unit 2)

ER-AA-2006 Lost Parts Evaluations 14

Procedures OP-AA-108-115 Operability Determination 22

Work Orders 04980773 07 1B DG Exhaust Leak at 8R Manifold 01/22/2020

71111.18 Calculations EMD-010068 Review of Seismic Qualification Report for Diesel Generator 0B

Associated Systems (Cooper Energy Services Report CES-

0351-2)

Corrective Action AR 04312321 1B DG Manifold Support Beam Missing Bolts 01/24/2020

Documents AR 04312334 1B Diesel Generator Manifold Alignment Issue 01/24/2020

Drawings KSV-24-11 Diesel Generator Manifold Exhaust (20 Cyl.) B

Engineering 0000630492 Alternate Detail for Diesel Generator Manifold Support 01/24/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Changes

Miscellaneous BAR-1-10-E4 Ovation System Alarm No.: 1-10-E4 2

71111.18 Miscellaneous CC-AA-309-1001- Design Analysis Cover Sheet Form 0

F-01

EC 617683 Design Considerations Summary 132

EC 617683 DCS Attachment D; Evaluation for Temporary Panel PA-TCP 0

Procedures BOP CX-99 Ovation Temporary Control Panel (TCP) Operations 0

Work Orders 04980773 07 Replace 1B Diesel Generator Manifold 01/27/2020

71111.19 Corrective Action AR 04314226 2CV01PB - Oil Leak During Pump Operation 01/31/2020

Documents AR 04315044 NRC ID-1CC01PA OB Bearing Oiler Not Plumb 02/03/2020

Work Orders 04836027 Low Power Physics Testing 03/26/2020

04988258 01 (NEIL) - 1CC01PA Comprehensive IST Reqmts for CC 01/31/2020

Pump

04992081 01 (NEIL) - 1B Diesel Generator Operability Surveillance 01/24/2020

04996664 01 (NEIL) 2CV01PB Group A IST Requirements for CV Pump 01/28/2020

71111.20 Miscellaneous B1R23 2 Month Readiness Review 01/09/2020

Procedures OP-AA-102-104 Unit 1 EOL De-Boration and Coastdown Strategy, 3

OP-AA-102-104 Ovation Temporary Control Panel, Attachment 2 3

71111.22 Calculations EC 622685 Diesel Generator Single Load Rejection Testing 0

Drawings LLRT-1PC-12 LLRT Drawing Penetration 1PC-12, Procedure 1BOSR 11/02/2001

6.1.1-8

LLRT-1PC-45 LLRT Drawing Penetration 1PC-45, Procedure 1BOSR 11/02/2001

6.1.1-8

Procedures 1BOSR 6.1.1-8 Unit 1 Primary Containment Type C Local Leakage Rate 14

Tests and IST Tests of Primary Sampling System

1BOSR 8.1.9-1 1A Diesel Generator Safe Shutdown Sequencer And Single 24

Load Rejection Test

Work Orders 04827466 01 (NEIL) 1AF01PA Comprehensive IST Rqmts for the Motor 03/03/2020

Driven

04827467 01 (NEIL) 1AF01PB Comprehensive IST Rqmts for the Diesel 03/03/2020

Driven

04834766 Automated Rod Drop Testing 03/25/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

05000161 01 (NEIL) 2B Diesel Driven AF Pump Monthly Surveillance 02/07/2020

71124.01 Corrective Action 04233626 Individual Received Unplanned Accumulated Dose Alarm 03/27/2019

Documents

Procedures NISP-RP-004 Radiological Posting and Labeling 1

RP-AA-460-002 Additional High Radiation Exposure Control 5

RP-AA-460-003 Access to HRA/LHRA and Contaminated Areas in Response 10

to a Potential or Actual Emergency

Radiation 2020-066768 Reactor Head Side View for Reactor Head PT and 03/12/2020

Surveys Inspection on Pen 3

20-066926 A/D Steam Generator Platform 03/13/2020

20-066938 D-Steam Generator Bowl 03/13/2020

20-066938 A-Steam Generator Bowl 03/13/2020

20-066768 Reactor Head Side View; Inside Containment 426' 03/12/2020

Radiation Work BY-1-20-00648 Core Barrel Moves 0

Permits (RWPs) BY-1-20-00710 Steam Generator Manway and Diaphragm Remove/Install 0

BY-2-19-00210 Pre Outage Containment Activities @ Mode1 - Outside 0

Missile Barrier Work Only

71124.05 Calibration 0018067 MGP Telepole 6608-081 Out of Tolerance 02/27/2019

Records 0023597 MGP Telepole 6608-33 03/19/2019

04574872 Surveillance Calibration of Auxiliary Building Vent Stack 03/10/2019

Wide Range Gas Radiation Monitor (WRGM) 2PR30J

04606764 Surveillance Calibration of Containment Building Fuel 08/10/2018

Handling Incident Radiation Monitor

04623408 Surveillance Calibration of High Range Containment 10/21/2018

Radiation Monitor 1AR20J

04701826 Surveillance Calibration of High Range Containment 11/18/2019

Radiation Monitor 2AR20J

04726551 Surveillance Calibration of auxiliary Building Ventilation 06/11/2019

Stack Effluent Radiation Monitor

333044 Eberline RM-14 03/13/2019

Mirion Calibration of Accuscan II WBC System at Exelon Byron 03/20/2019

Technologies Generating Station

Mirion Calibration of the Accuscan2 WBC System at the Exelon 03/19/2019

Technologies Generating Station

Inspection Type Designation Description or Title Revision or

Procedure Date

Mirion Calibration of the Fastscan1 WBC System at the Exelon 03/19/2019

Technologies Byron Generating Station

Mirion Calibration Sources and Library File Information 01/01/2018

Technologies

Corrective Action AR 04316061 NRC ID: Recommend RP Review IMD Test Report 02/06/2020

Documents

Corrective Action AR 04315737 NRC ID: Recommend Old Barium-133 Source be Replaced 02/06/2020

Documents

Resulting from

Inspection

Miscellaneous 11963 RP-AA-700 Out of Tolerance Report RO-20 08/12/2019

2689 RP-AA-700 Out of Tolerance Report for RO-20 02/05/2019

5032 RP-AA-700 Out of Tolerance Report RM-14 05/22/2019

Procedures RP-AA-232 Operation of Whole Body Counter (WBC) Using APEX-Invivo 1

71151 Procedures BY-MSPI-001 Reactor Oversight Program MSPI Basis Document 19

71152 Corrective Action AR 04272503 Notification of Code Nonconformance for Replacement SGS 08/16/2019

Documents AR 04304789 Part 21 - Westinghouse Thermal Sleeves 12/18/2019

AR 04320104 WEC NSAL-20-1, RVH CRDM Penetration Thermal Sleeve 02/21/2020

Failure

AR 04322068 Westinghouse Justification to Postpone NSAL-20-1 02/27/2020

Inspections

AR 04325984 Discrepancy Btwn UFSAR and Vendor Safety Class 03/12/2020

AR 04327728 Thermal Sleeve at Pen-34 Lowered Beyond Specific Eval 03/18/2020

Value

Engineering 0000630321 Issue Revision 009 to Design Specification 18-1229648 for 01/17/2020

Changes U1 BWXT Replacement Steam Generators

Miscellaneous LTR-RIDA-20-32 Byron Unit 1 CRDM Thermal Sleeve Cracking Inspection 0

Deferral

Nuclear Safety Reactor Vessel Head Control Rod Drive Mechanism 02/14/2020

Advisory Letter Penetration Thermal Sleeve Cross-Sectional Failure

(NSAL)-20-1

20

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